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National Concrete Masonry Association Letter to Chairman Issa - January 7, 2011

National Concrete Masonry Association Letter to Chairman Issa - January 7, 2011

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Published by CREW
In December 2010, Representative Darrell Issa, Chairman of the U.S. House Committee on Oversight and Government Reform, sent a letter to over 150 companies, trade groups, and research organizations asking them to identify federal regulations that adversely affect job growth. This letter is one of the many responses that CREW has collected and posted for public review.
In December 2010, Representative Darrell Issa, Chairman of the U.S. House Committee on Oversight and Government Reform, sent a letter to over 150 companies, trade groups, and research organizations asking them to identify federal regulations that adversely affect job growth. This letter is one of the many responses that CREW has collected and posted for public review.

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Published by: CREW on Jan 28, 2011
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04/06/2012

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 National Concrete Masonry Association Letter to Rep. Issa Page
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January 7, 2011The Honorable Darryl IssaCommittee on Oversight and Government Reform2157 Rayburn House Office BuildingWashington, DC 20515-6143Dear Chairman Issa,The National Concrete Masonry Association is pleased that your committee is examining existingand proposed regulations that negatively impact the economy and jobs and that you have askedfor our assistance in identifying examples and explaining their effect. NCMA, established in 1918,is the national trade association representing the concrete masonry industry. Collectively, themasonry industry represents $23 billion in construction annually and employs 550,000 people inall 50 states.Presently, two regulations are in the rulemaking process at EPA and OSHA and another being“reinterpreted” at EPA and OAHA that, if they turn out as intended by those agencies, will havesignificantly negative effect upon job growth in the concrete masonry manufacturing industry:Coal Combustion Residuals (CCRs), Disposal of – EPA Rulemaking.Issue. The EPA, with heavy encouragement from forces determined to destroyAmerica’s coal industry by political and regulatory means, has zeroed in on the electricpower generation industry, which uses an immense amount of coal to produce electricity,seeking to regulate disposal of coal combustion residues (CCRs) under RCRA as ahazardous waste. Associated high handling and disposal costs from such a rule wouldincrease the cost of electric power production as electricity producers convert existingfacilities to comply with hazardous waste regulations or convert from coal to other fuels.These costs would be passed on to all consumers, including producers of concretemasonry. In addition to paying more for electricity, concrete masonry producers thatconsume a considerable amount of recycled fly ash would face the even greater burdenof retrofitting plants and equipping workers to handle a “hazardous” waste. EPA appearsto favor hazardous waste regulation of CCRs, in spite of intense opposition from industry,consumers, and virtually all the States and other federal agencies (e.g., DOE, DOI,Department of Agriculture), and, if that were not enough, two of its own previousregulatory determinations that fly ash does not warrant regulation as a hazardous waste.Background. CCR (fly ash) is used in considerable quantity in the manufacture andplacement of concrete masonry in the construction industry. Substitute materials aremore expensive and less effective than fly ash, putting our industry at a competitive andpossibly fatal disadvantage. Despite significant opposition, EPA has continuedundeterred for several years and rulemaking is expected to culminate with promulgationof a final rule later this year.Position. NCMA strongly opposes regulation of fly ash as a hazardous waste, with orwithout special use exemption.
 
 National Concrete Masonry Association Letter to Rep. Issa Page
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Impact of Job Growth if Adopted. It is conceivable that a sizeable portion of the concretemasonry industry would be significantly impacted by this rule because the expense ofhandling fly ash as a hazardous waste. Resulting increased costs could drive concreteusers to alternate construction means like building with wood and steel, which could beinferior to concrete products for their applications, more expensive, or both. Job losscould be overwhelming and occur in every state, dramatically affecting an industryalready crippled by the lingering effects of the recession.Occupational Exposure to Crystalline Silica – OSHA Rulemaking
 
Issue. OSHA is scheduled to publish a proposed standard for occupational exposure tocrystalline silica in April. We expect that it will cut in half the existing permissibleexposure limit (PEL) for crystalline silica. Workers exposed to excessive levels ofrespirable crystalline silica for long periods of time can develop silicosis and, according toOSHA, may face an increased risk of lung cancer as well. But the evidence does notestablish that these increased risks will be found in workers whose exposures aremaintained at or below the current PEL.Background. Though OSHA has been working on a crystalline silica standard for manyyears, it has not sponsored a study to determine whether American workers today are atincreased risk of developing silicosis (or possibly lung cancer) if their exposures do notexceed the current PEL. Indeed, there is good reason to believe that complying with thecurrent PEL is sufficient to prevent cases of silicosis. And even if crystalline silicaexposures can cause lung cancer, a position that remains controversial, exposures thatare not high enough to cause silicosis will not increase the risk of lung cancer either.Position. Health and welfare of workers in our industry is of utmost importance. Ifscientific studies showed that reducing the PEL is necessary to reduce cases of silicosisand risks of lung cancer, NCMA would be more receptive to OSHA’s expected proposal.However, we do not believe the body of science shows that to be the case. The publicwould be better served, in our opinion, if OSHA focused its resources upon ensuring thatall employers are complying with the current PEL. This, we believe, will adequatelyaddress any health risks associated with exposure to crystalline silica. Thoughsupplementing the current standard with certain ancillary requirements, e.g., exposuremonitoring and medical surveillance, is a separate question, but cutting the current PELin half is not justified by supporting evidence at this time.
 
Impact on Job Growth if Adopted. Any further lowering of the PEL will only lead toincreased costs for employers, passed-on costs to consumers, lost jobs for workers, andmore community hardship – all without doing a thing to provide more protection toworkers.Workplace Noise Control Rule, Reinterpretation -- OSHAIssue. OSHA has announced its intent to change its official interpretation of existingfederal noise exposure standards in a way that would, among other things, fundamentallychange the hierarchy of controls to now
 
require “engineering and administrative controls”to maintain noise levels below a minimum daily dose. These controls mean noisecancellation technologies for the individual worker and broad noise reduction for theentire worksite or plant setting. Assuming that meeting these requirements istechnologically possible at all, the costs to employers in our industry would beastronomical.Background. Construction and manufacturing work sites are inherently noisy. Employershave long recognized, if for none other than a productivity standpoint, the importance of

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